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OCR: RA1 Interual Revenue Service General Counsel's Memorandum 24626 {1945} GCIGHS -396092 In re: DEPUTY COMMISSIONER BLISS: Refererce is made to your of December B 1944 (MT-ST -RR) transmitting for review of proposed ruling with res pect whether the renunciation by her inte est under he will her deceased husband would corstitute gif under the Federal tax statute It is the view of this office that the renunciation f her interests under the will, the absence other material circumstances or any affimative acts 10 the ed of the MOPiM [illegible] the subeequent disposition Of the property involved [illegible] to establish donative intent, would not constitute gift This office, therefore, in accord with the conclusions reached in the proposed ruling ietter, but suggested that for the purpose qualif ...